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SEC Petition Evaluation Report

Petition SEC-00169

Report Rev #: 0 Report Submittal Date: April 28, 2010

Subject Expert(s): Vincent King, Joseph Guido, Raymond Weaver

Site Expert(s): N/A

Petitioner Administrative Summary

Petition Under Evaluation

Petition # Petition 

Type

Petition A

Receipt Date DOE/AWE Facility Name

SEC-00169 83.14 April 19, 2010 BWX Technologies, Inc. (Virginia)

NIOSH-Proposed Class Definition

All Atomic Weapons Employer employees who worked at BWX Technologies, Inc., in Lynchburg, Virginia, 

during the periods:

• from January 1, 1959 through December 31, 1959; or

• from January 1, 1968 through December 31, 1972

for a number of work days aggregating at least 250 work days, occurring either solely under this employment, 

or in combination with work days within the parameters established for one or more other classes of employees 

included in the Special Exposure Cohort.

Related Petition Summary Information

SEC Petition Tracking #(s) Petition Type DOE/AWE Facility Name Petition Status

None

Related Evaluation Report Information

Report Title DOE/AWE Facility Name

None

ORAU Lead Technical Evaluator: Vincent King ORAU Peer Review Completed By: Michael Kubiak

Peer Review Completed By: [Signature on file] 4//29/2010

LaVon Rutherford Date

SEC Petition Evaluation Reviewed By: [Signature on file] 4/30/2010

J. W. Neton Date

SEC Evaluation Approved By: [Signature on file] 5/3/2010

Stuart Hinnefeld Date
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Evaluation Report Summary: SEC-00169, BWX Technologies

This evaluation report by the National Institute for Occupational Safety and Health (NIOSH) 

addresses a class of employees proposed for addition to the Special Exposure Cohort (SEC) per the 

Energy Employees Occupational Illness Compensation Program Act of 2000, as amended, 42 U.S.C. 

§ 7384 et seq. (EEOICPA) and 42 C.F.R. pt. 83, Procedures for Designating Classes of Employees 

as Members of the Special Exposure Cohort Under the Energy Employees Occupational Illness 

Compensation Program Act of 2000.

NIOSH-Proposed Class Definition

All AWE employees who worked at BWX Technologies, Inc. in Lynchburg, Virginia, during the 

periods:

• from January 1, 1959 through December 31, 1959; or

• from January 1, 1968 through December 31, 1972

for a number of work days aggregating at least 250 work days, occurring either solely under this 

employment, or in combination with work days within the parameters established for one or more 

other classes of employees included in the Special Exposure Cohort.

Feasibility of Dose Reconstruction Findings

NIOSH lacks sufficient information, which includes sufficient biological monitoring data, air 

monitoring information, and process and radiological source term information to allow it to estimate 

with sufficient accuracy the potential internal exposures to fission and activation products, uranium, 

and thorium to which the proposed class may have been subjected. NIOSH finds that it is likely 

feasible to reconstruct occupational medical dose for BWX Technologies, Inc., workers with 

sufficient accuracy.

The NIOSH dose reconstruction feasibility findings are based on the following:

• Principal sources of internal and external radiation for members of the proposed class included 

exposures to fission and activation products, uranium of varying degrees of enrichment, and 

thorium. Associated BWX Technologies, Inc., operations included fuel fabrication, uranium 

recovery, and commercial reactor and laboratory operations.

• Urine sampling at BWXT during the 1959 AWE period used fluorometric analysis for evaluating 

uranium exposures to workers; such analysis is insufficient for the evaluation of enriched uranium 

intakes unless enrichment values are known. Data available to NIOSH do not provide adequate 

enrichment values for 1959.

• BWXT did not directly monitor worker exposures to thorium using bioassay. Thorium intakes 

may be inferred from bioassay-derived uranium intakes if the relative activities of thorium and 

uranium can be established; however, the records available to NIOSH for 1959 do not definitively 

show that thorium was always used in conjunction with uranium at BWXT.
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• For individuals who worked where high-activity commercial materials were handled and stored, 

personnel internal dose monitoring records were not found for the first AWE operational period 

(1959), and were found for less than half the workers for the second operational period (1968 

through 1972).

• NIOSH does not have access to sufficient personnel monitoring, workplace monitoring, or source 

term data to estimate unmonitored internal exposures for BWXT workers during the periods of 

AWE operations from January 1, 1959 through December 31, 1959, or from January 1, 1968 

through December 31, 1972, regardless of assigned work location.

• Pursuant to 42 C.F.R. § 83.13(c)(1), NIOSH determined that there is insufficient information to 

either: (1) estimate the maximum radiation dose, for every type of cancer for which radiation 

doses are reconstructed, that could have been incurred under plausible circumstances by any 

member of the class; or (2) estimate the radiation doses of members of the class more precisely 

than a maximum dose estimate.

Although NIOSH found that it is not possible to completely reconstruct radiation doses for the 

proposed class, NIOSH intends to use any internal and external monitoring data that may become 

available for an individual claim (and that can be interpreted using existing NIOSH dose 

reconstruction processes or procedures). Therefore, dose reconstructions for individuals employed at 

BWX Technologies, Inc., during the periods from January 1, 1959 through December 31, 1959; or 

January 1, 1968 through December 31, 1972, but who do not qualify for inclusion in the SEC, may be 

performed using these data as appropriate.

Health Endangerment Determination

The NIOSH evaluation did not identify any evidence supplied by the petitioners or from other 

resources that would establish that the class was exposed to radiation during a discrete incident likely 

to have involved exceptionally high-level exposures, such as nuclear criticality incidents or other 

events involving similarly high levels of exposures. However, the evidence reviewed in this 

evaluation indicates that some workers in the class may have accumulated chronic radiation exposures 

through intakes of natural uranium, enriched uranium, and thorium and from direct exposure to 

radioactive materials. Therefore, 42 C.F.R. § 83.13(c)(3)(ii) requires NIOSH to specify that health 

may have been endangered for those workers covered by this evaluation who were employed for a 

number of work days aggregating at least 250 work days within the parameters established for this 

class or in combination with work days within the parameters established for one or more other 

classes of employees in the SEC.
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Table of Contents

Evaluation Report Summary: SEC-00169, BWX Technologies............................................................. 3

1.0 Purpose and Scope....................................................................................................................... 7

2.0 Introduction ................................................................................................................................. 7

3.0 NIOSH-Proposed Class Definition and Petition Basis................................................................ 8

4.0 Radiological Operations Relevant to the Proposed Class ........................................................... 8

4.1 Operations Description....................................................................................................... 9

4.2 Radiation Exposure Potential from Operations................................................................ 10

4.3 Time Period Associated with Radiological Operations.................................................... 12

4.4 Site Locations Associated with Radiological Operations ................................................ 12

4.5 Job Descriptions Affected by Radiological Operations ................................................... 13

5.0 Summary of Available Monitoring Data for the Proposed Class.............................................. 13

5.1 Data Capture Efforts and Sources Reviewed ................................................................... 13

5.2 Worker Interviews............................................................................................................ 14

5.3 Internal Personnel Monitoring Data ................................................................................. 14

5.4 External Personnel Monitoring Data ................................................................................ 17

5.5 Workplace Monitoring Data............................................................................................. 20

5.5.1 Breathing zone air sampling................................................................................. 20

5.5.2 Dust studies .......................................................................................................... 20

5.6 Radiological Source Term Data ....................................................................................... 20

6.0 Feasibility of Dose Reconstruction for the Proposed Class ...................................................... 21

6.1 Feasibility of Estimating Internal Exposures ................................................................... 21

6.2 Feasibility of Estimating External Exposures .................................................................. 22

6.3 Class Parameters Associated with Infeasibility................................................................ 24

7.0 Summary of Feasibility Findings for Petition SEC-00169........................................................ 24

8.0 Evaluation of Health Endangerment for Petition SEC-00169................................................... 25

9.0 NIOSH-Proposed Class for Petition SEC-00169 ...................................................................... 25

10.0 Evaluation of Second Similar Class.......................................................................................... 26

11.0 References ................................................................................................................................. 27

Attachment One: Data Capture Synopsis.............................................................................................. 31
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Tables

4-1: Timeline for Facilities and Operations at BWXT.......................................................................... 10

5-1: NNFD Energy Employees Internal Monitoring Information......................................................... 15

5-2: LTC Energy Employees Internal Monitoring Information ............................................................ 16

5-3: LTC Energy Employees Internal Exposure Monitoring by Radionuclide and Type..................... 16

5-4: NNFD Energy Employees External Monitoring Information........................................................ 17

5-5: NNFD Energy Employees Annual External Dose Summary ........................................................ 18

5-6: LTC Energy Employees External Monitoring Information........................................................... 19

5-7: LTC Energy Employees Annual External Dose Summary............................................................ 19
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SEC Petition Evaluation Report for SEC-00169

ATTRIBUTION AND ANNOTATION: This is a single-author document. All conclusions drawn from 

the data presented in this evaluation were made by the ORAU Team Lead Technical Evaluator: 

Vincent King; MJW Corporation. The rationales for all conclusions in this document are explained in 

the associated text.

1.0 Purpose and Scope

This report evaluates the feasibility of reconstructing doses for employees who worked at a specific 

facility during a specified time. It provides information and analysis germane to considering a petition 

for adding a class of employees to the Congressionally-created SEC.

This report does not make any determinations concerning the feasibility of dose reconstruction that 

necessarily apply to any individual energy employee who might require a dose reconstruction from 

NIOSH, with the exception of the employee whose dose reconstruction could not be completed, and 

whose claim consequently led to this petition evaluation. The finding in this report is not the final 

determination as to whether or not the proposed class will be added to the SEC. This report will be 

considered by the Advisory Board on Radiation and Worker Health (the Board) and by the Secretary 

of Health and Human Services (HHS). The Secretary of HHS will make final decisions concerning 

whether or not to add one or more classes to the SEC in response to the petition addressed by this 

report.

This evaluation, in which NIOSH provides its findings both on the feasibility of estimating radiation 

doses of members of this class with sufficient accuracy and on health endangerment, was conducted in 

accordance with the requirements of EEOICPA and 42 C.F.R. § 83.14.

2.0 Introduction

Both EEOICPA and 42 C.F.R. pt. 83 require NIOSH to evaluate qualified petitions requesting that the 

Department of Health and Human Services add a class of employees to the SEC. The evaluation is 

intended to provide a fair, science-based determination of whether it is feasible to estimate, with 

sufficient accuracy, the radiation doses of the proposed class of employees through NIOSH dose 

reconstructions.

1

NIOSH is required to document its evaluation in a report, and to do so, relies upon both its own dose 

reconstruction expertise as well as technical support from its contractor, Oak Ridge Associated 

Universities (ORAU). Once completed, NIOSH provides the report to both the petitioners and the 

Advisory Board on Radiation and Worker Health. The Board will consider the NIOSH evaluation 

report, together with the petition, comments of the petitioner(s) and such other information as the 

Board considers appropriate, to make recommendations to the Secretary of HHS on whether or not to 

add one or more classes of employees to the SEC. Once NIOSH has received and considered the 

advice of the Board, the Director of NIOSH will propose a decision on behalf of HHS. The Secretary 

 1 NIOSH dose reconstructions under EEOICPA are performed using the methods promulgated under 42 C.F.R. pt. 82 and 

the detailed implementation guidelines available at http://www.cdc.gov/niosh/ocas.
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of HHS will make the final decision, taking into account the NIOSH evaluation, the advice of the 

Board, and the proposed decision issued by NIOSH. As part of this final decision process, the 

petitioner(s) may seek a review of certain types of final decisions issued by the Secretary of HHS.

2

3.0 NIOSH-Proposed Class Definition and Petition Basis

The NIOSH-proposed class includes all AWE employees who worked at BWX Technologies, Inc. in 

Lynchburg, Virginia, during the periods:

• from January 1, 1959 through December 31, 1959; or

• from January 1, 1968 through December 31, 1972

for a number of work days aggregating at least 250 work days, occurring either solely under this 

employment, or in combination with work days within the parameters established for one or more 

other classes of employees included in the Special Exposure Cohort. During this period, employees at 

this facility were involved with fuel fabrication, uranium recovery, and commercial reactor and 

laboratory operations.

The evaluation responds to Petition SEC-00169 which was submitted by an EEOICPA claimant 

whose dose reconstruction could not be completed by NIOSH due to a lack of sufficient dosimetryrelated information. NIOSH’s determination that it is unable to complete a dose reconstruction for an

EEOICPA claimant is a qualified basis for submitting an SEC petition pursuant to 42 C.F.R. § 

83.9(b).

4.0 Radiological Operations Relevant to the Proposed Class 

The following subsections summarize the radiological operations at BWX Technologies, Inc., 

(BWXT) in Lynchburg, Virginia during its three AWE operations periods from January 1, 1959 

through December 31, 2001 and the information available to NIOSH to characterize particular 

processes and radioactive source materials. Using available sources, NIOSH has attempted to gather 

process and source descriptions, information regarding the identity and quantities of radionuclides of 

concern, and information describing processes through which the radiation exposures of concern may 

have occurred and the physical environment in which they may have occurred. The information 

included within this evaluation report is meant only to be a summary of the available information.

 2 See 42 C.F.R. pt. 83 for a full description of the procedures summarized here. Additional internal procedures are 

available at http://www.cdc.gov/niosh/ocas.
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4.1 Operations Description

The EEOICPA facility designation for BWX Technologies, Inc., includes two separately-licensed 

locations in Lynchburg, Virginia, that have performed work for a variety of Atomic Energy 

Commission (AEC) and DOE projects (Public Hearings, 1959). During various periods of the site’s 

operating history, the Nuclear Navy Fuels Division (or NNFD) has been referred to as the ‘main plant’ 

at Mount Athos (DOE, 2010), the Nuclear Facilities Plant (NFP), the Nuclear Products Division 

(NPD), or the Nuclear Operations Group – Lynchburg (NOG-L) (Personal Communication, 2010a). 

The second location is the Lynchburg Technology Center (LTC), formerly called the Lynchburg 

Research Center (LRC) (Personal Communication, 2010a). These two separate BWXT locations are 

referred to as NNFD and LTC in this document.

NNFD Facility

The NNFD facility was built in 1956 and has continuously operated through the present (BWXT 

History, 1994). Operated by the Babcock and Wilcox Company, NNFD participated in the AEC's 

Oxide Pellet Fabrication Program, which was managed by the New York Operations Office in 1959 

(HASL-70, 1959). Records indicate that shipments of enriched uranium were made to and from the 

Fernald facility during the years 1968-1972. The company also recovered highly-enriched uranium 

from weapons scrap received from the DOE's Oak Ridge facility between 1985 and 1996. In 1997,

the Babcock & Wilcox Company facility in Lynchburg became the BWX Technologies facility. From 

1998 to 2000, the company fulfilled a contract for the recovery of enriched uranium from scrap 

materials containing beryllium. Records available to NIOSH indicate that the Lynchburg plant also 

participated in the DOE-sponsored Project Sapphire from 1995 through March 2001, which entailed 

downblending enriched uranium from the government of Kazakhstan (DOE, 2010; Sapphire, 

undated).

NNFD activities for all operational periods primarily involved fuel fabrication using enriched 

uranium; activities also involved thorium or uranium-thorium mixtures in 1959. Throughout the site’s

history, uranium enrichment was stated to be typically >90% (BWXT History, 2008), although 

enrichments as low as approximately 4% were also used (HASL-70, 1959; Shipment Analysis, 1969; 

Shipment Request, 1959), and small amounts of depleted and natural uranium were also on site during 

downblending operations (BWXT History, 2008). Investigation reports in claimant DOE files 

provided to NIOSH also occasionally include a BWXT internal dose assessment form (Form RP-04-

01), which included checkbox items for 20%, 93%, and 97% U-235, indicating that these were likely 

to be commonly-encountered enrichments. Enrichment for one process evaluated during the 1959 

operational period is recorded as 4.2% (HASL-70, 1959), but NIOSH has no indication that this value 

adequately represents the range of NNFD’s possible uranium work in 1959. 

LTC Facility

Construction of the LTC facility began in 1956 (BWXT History, 1994). Work at the LTC location 

primarily involved reactor research, fuel testing, and hot cell work (BWXT History, 2008). The LTC 

is comprised of four main buildings (A, B, C, and D) and several support building and areas (e.g., 

Liquid Waste Disposal, Building J, silos). Building A was the reactor building. Reactors were in 

operation from 1957 through 1983 (Reactor CX-1 began operation in 1957; Reactors CX10, CX-19, 

CX-12, and R-47 began operations in 1958). All reactors were decommissioned by 1986. Building B 

was constructed in the 1960s and housed offices, the hot cells, and a laboratory that provided sample 
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analysis for all the radiological facilities. Building B is currently in operation. Building C served 

mainly as a fuel-processing test facility and was in service from 1962 until it was decommissioned in 

1983. Building D mainly provided administrative support and an X-ray facility. In the information 

available to NIOSH, the only evidence of LTC directly performing weapons-related work are 

indications that the analytical laboratory provided sample analysis services for the BWXT NNFD 

facility (Personal Communication, 2010a). LTC laboratories included the Plutonium Development 

Lab (PDL), the Nuclear Development Center (NDC), and the Criticality Experiment Lab (CEL) 

(BWXT History, 2008).

4.2 Radiation Exposure Potential from Operations

The potential for internal and external radiation dose existed at both the NNFD and LTC facilities. A 

breakdown of facilities and activities with the potential for radiation exposure is shown in Table 4-1.

Table 4-1: Timeline for Facilities and Operations at BWXT

Building/Facilities Operation Type Start of Operations End of Operations

LTC Facility

Building A Research and Development 

activities with radioactive 

materials, reactors

1956 1984 (Materials License, 1987), 

final decommissioning June 1986 

(BWXT History, 1994)

Subassembly 

room 1

Unencapsulated fuel (uranium 

and thorium)

1957 Unrestricted release 1984 

(Materials License, 1987)

CX-1 reactor 3/20/1957 6/6/1973 (License Termination, 

1986)

CX-10 reactor Constructed 1957 

(operations began 

1/22/1958)

September 1983 (License 

Termination, 1986)

Subassembly 

room 2

Unencapsulated fuel (uranium 

and thorium)

1958 Unrestricted release 1984 

(Materials License, 1987)

R-47 reactor 1958 July 1982 (License Termination, 

1986)

Lynchburg pool 

reactor (LPR)

reactor 1958 1981 (Materials License, 1987)

CX-19 reactor 1/22/1958 6/6/1973 (License Termination, 

1986)

CX-12 reactor 9/24/1958 1971 (Materials License, 1987)

Babcock & 

Wilcox Test 

Reactor 

(BAWTR)

reactor Construction began 1962; 

operations began 

1/28/1964

12/22/1972 (Materials License, 

1987)

Building B Laboratory analysis for all 

BWXT facilities, hot cells, 

Cask Handling Area (CHA), 

Liquid Waste Disposal 

Facility (LWDF), storage of 

highly activated/contaminated 

materials, fuel rod 

examination

1960s (BWXT History, 

1994)

present
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Table 4-1: Timeline for Facilities and Operations at BWXT

Building/Facilities Operation Type Start of Operations End of Operations

Building C (License 

SNM-778)

Fuel research and 

development

1962 1983 (BWXT History, 1994)

Thorium fuel research 1962 1966 (BWXT History, 1994; 

BWXT History, 2009)

Thorium – U-233 fuel 

research

1964 1964 (BWXT History, 1994)

Plutonium fuel research 1966 1971 (BWXT History, 1994)

Uranium fuel research 1971 1983 (BWXT History, 1994)

NNFD Facility

Main facility Uranium and thorium fuel 

fabrication 

1956 1963 (thorium) (BWXT History, 

2009)

Present (uranium)

Project Sapphire, 

downblending of foreign HEU 

to fuel grade enrichments

Shipments received 1995

Downblending starts 

September 1996

March 2000 (NucNews, 2002;

NucNews, 2003; Sapphire, 

undated)

NNFD Exposures

Based on the site operations outlined in Section 4.1, sources of exposure at NNFD included photon 

and electron radiation emitted from both AEC-related and commercial uranium at various degrees of 

enrichment and thorium. The primary source of internal radiation exposure at the NNFD facility was 

exposure to airborne enriched uranium and thorium generated during fuel fabrication operations 

(BWXT History, 2008).

LTC Exposures

Sources of external exposure at LTC included photon, electron, and neutron radiation associated with 

reactor operations and maintenance, and laboratory and hot-cell operations. External doses were 

higher during earlier years (late 1950s to early 1960s) when thorium-bearing fuels were processed; 

external doses at LTC were also higher than those for NNFD due to the presence of fission products 

(BWXT History, 2008). Examples of LTC activities that involved external exposures include (BWXT 

History, 1994):

• Construction of large quantities of plate-type enriched uranium and metallic thorium fuel 

assemblies

• Criticality experiments with large quantities of uranium or uranium-thorium fuels

• Laboratory analysis of fuel streams for various Lynchburg operations, including support of

downblending contracts at the NNFD plant

• Storage, repackaging, and examination of DOE special nuclear material (SNM) waste, fuel 

remnants, and related fission products

• Fuel rod examination, including thoriated fuel
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• Hot cell activities; examination of irradiated equipment and spent nuclear fuel

• Cask-handling activities involving receipt of highly-radioactive components such as fuel 

assemblies

• Storage of highly-contaminated and highly-activated materials

• Neutron radiation from reactor operations and/or Pu-Be neutron sources

The primary sources of internal radiation exposure at the LTC facility were fissile materials such as 

airborne enriched uranium, thorium, plutonium, and U-233 generated during fuel fabrication, testing, 

and analysis operations; transuranics during sample analysis and materials analysis; irradiated fuels 

and materials during destructive testing and analysis; fissile materials and/or fission and activation 

products during scrap recovery; and fission and activation products during sample analysis, hot cell 

operations, and waste processing (BWXT History, 1994)

4.3 Time Period Associated with Radiological Operations

Per the DOE Office of Health, Safety and Security, the time periods associated with AWE operations 

at the BWXT site are 1959; 1968 through 1972; and 1985 through 2001 (DOE, 2010). NIOSH has 

discovered no additional data to support more specific dates for the start and stop of these AWE 

operations periods. Therefore, AWE work at BWXT is assumed to have occurred during the periods 

from January 1, 1959 through December 31, 1959; from January 1, 1968 through December 31, 1972; 

and from January 1, 1985 through December 31, 2001.

4.4 Site Locations Associated with Radiological Operations

NIOSH has determined that both commercial operations and operations with AEC-related materials 

occurred at the NNFD and LTC facilities. NNFD operations involved enriched uranium for all 

operational periods, and thorium and thorium-uranium alloys in 1959. Documentation available to 

NIOSH for either facility does not indicate any definite boundaries between radiological and 

non-radiological areas for the periods under evaluation. Interviews conducted by NIOSH with BWXT 

energy employees indicate that workers sometimes travelled between the two BWXT sites (Personal 

Communication, 2010b). NIOSH has reviewed the available monitoring and employment records for 

the interviewed energy employees and has determined that worker movement between the sites often 

is not accurately represented in the individual records. Several workers interviewed indicated that 

they worked at both facilities over their work histories, but records made available to NIOSH did not 

identify work site locations or transfers between work sites that correlate with the information 

provided in the interview for those workers. No additional program documentation was found in the 

available records that allowed NIOSH to identify protocols or procedures for determining potential 

worker movements between the NNFD and LTC sites. NIOSH has determined that the site-specific 

and claimant-specific data available are insufficient to allow NIOSH to characterize worker 

movements throughout or between the two BWXT facilities. NIOSH is therefore unable to define 

individual worker exposure scenarios based on specific work locations within the BWXT facilities 

during the periods under evaluation.
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4.5 Job Descriptions Affected by Radiological Operations

NIOSH has determined that the site-specific and claimant-specific data available for the LTC and 

NNFD facilities of BWXT for the time period under evaluation are insufficient to allow NIOSH to 

determine that any specific work group was not potentially exposed to radioactive material releases or 

possible subsequent contamination.

NIOSH has insufficient information associating job titles and/or job assignments with specific 

radiological operations or conditions. Without such information, NIOSH is unable to define potential 

radiation exposure conditions based on worker job descriptions.

5.0 Summary of Available Monitoring Data for the Proposed Class

The primary data used for determining internal exposures are derived from personal monitoring data, 

such as urinalyses, fecal samples, and whole-body counting results. If these are unavailable, the air 

monitoring data from breathing zone and general area monitoring are used to estimate the potential 

internal exposure. If personal monitoring and breathing zone area monitoring are unavailable, internal 

exposures can sometimes be estimated using more general area monitoring, process information, and 

information characterizing and quantifying the source term.

This same hierarchy is used for determining the external exposures to the cancer site. Personal 

monitoring data from film badges or thermoluminescent dosimeters (TLDs) are the primary data used 

to determine such external exposures. If there are no personal monitoring data, exposure rate surveys, 

process knowledge, and source term modeling can sometimes be used to reconstruct the potential 

exposure.

A more detailed discussion of the information required for dose reconstruction can be found in 

OCAS-IG-001, External Dose Reconstruction Implementation Guideline, and OCAS-IG-002, Internal 

Dose Reconstruction Implementation Guideline. These documents are available at: 

http://www.cdc.gov/niosh/ocas/ocasdose.html.

5.1 Data Capture Efforts and Sources Reviewed 

As a standard practice, NIOSH completed an extensive database and Internet search for information 

regarding BWXT. The database search included the DOE Legacy Management Considered Sites 

database, the DOE Office of Scientific and Technical Information (OSTI) database, the Energy 

Citations database, the Atomic Energy Technical Report database, and the Hanford Declassified 

Document Retrieval System. In addition to general Internet searches, the NIOSH Internet search 

included OSTI OpenNet Advanced searches, OSTI Information Bridge Fielded searches, Nuclear 

Regulatory Commission (NRC) Agency-wide Documents Access and Management (ADAMS) web 

searches, the DOE Office of Human Radiation Experiments website, and the DOE-National Nuclear 

Security Administration-Nevada Site Office-search. Attachment One contains a summary of BWXT 

documents. The summary specifically identifies data capture details and general descriptions of the 

documents retrieved.
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In addition to the database and Internet searches listed above, NIOSH identified and reviewed 

numerous data sources to determine information relevant to determining the feasibility of dose 

reconstruction for the class of employees under evaluation. This included determining the availability 

of information on personal monitoring, area monitoring, industrial processes, and radiation source 

materials. The following subsections summarize the data sources identified and reviewed by NIOSH.

5.2 Worker Interviews

To obtain additional information, NIOSH interviewed 36 former BWXT employees.

• Personal Communication, 2010a, Personal Communication with BWXT Health Physicist; 

Telephone Interview by ORAU Team; March 11, 2009; SRDB Ref ID: 61504 

• Personal Communication, 2010b, Personal Communication with various BWXT employees; 

Telephone Interviews by ORAU Team with 34 former BWXT employees to verify employment

information; March 23-25, 2010; SRDB Ref ID: 80148 

• Personal Communication, 2010c, Personal Communication with a BWXT employee; Telephone 

Interview by ORAU Team; March 30, 2010; SRDB Ref ID: 80182 

As stated in Section 4.4, these interviews verified that workers sometimes travelled between the 

NNFD and LTC sites even though such movements could not be identified from the individual or 

program records available to NIOSH. 

5.3 Internal Personnel Monitoring Data

NNFD Facility

BWXT internal monitoring records evaluated by NIOSH typically included urinalysis for uranium 

(which was performed from the beginning of AWE operations).

Th-232 was in use at BWXT from the beginning of operations through February 1963 (BWXT 

History, undated). Although monitoring and urinalysis for Th-232 intakes was initially planned at the 

beginning of site operations (Frazier, 1956), the inability to correlate urinalysis results to body 

burdens of thorium led to the decision not to implement thorium urinalysis (Frazier, 1956; BWXT 

History, 2009). Consequently, for the 1959 operational period, worker exposures to thorium were not 

monitored directly by bioassay methods. Thorium intakes may be inferred from bioassay-derived 

uranium intakes if the relative activities of thorium and uranium can be established; however, the few 

records available to NIOSH for this period cannot definitively show that thorium was always used in 

conjunction with uranium. One feasibility study from 1959 (Feasibility Report, 1959) provides a 

uranium fraction of 5.93% in a uranium-thorium mixture, but this does not address other mixtures that 

may have been encountered. 
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Routine urine samples were evaluated for uranium content by fluorometric analysis from the 

beginning of operations through May 1965, with results reported in micrograms of uranium per day. 

Fluorometric analysis was also used to analyze baseline urine samples (called “background” samples) 

for all periods. (BWXT History, 2008). Because fluorometric analysis evaluates uranium content on a 

mass basis, it is ineffective at determining intakes of enriched uranium unless the enrichment value is 

also known.

Gross alpha counting for total uranium was performed from 1964 through 1991, with units initially 

reported in disintegrations per minute (dpm) per day, and later in picocuries per liter (pCi/L). Earlier 

records in dpm/day were often converted to pCi/L (BWXT used 1.4 liters per day excretion and 2.22 

dpm/pCi for this conversion). Records show some samples were also analyzed for isotopic uranium 

during later periods. After November 1994, isotopic urinalysis for uranium was performed by 

Teledyne Brown (BWXT History, 2008).

Chest counting was performed for U-235 with results reported in micrograms of U-235 (BWXT 

History, 2008).

Evaluation of uranium intakes using personnel monitoring was supplemented by breathing zone air 

sampling as discussed below in Section 5.5.

Consistent with the source term information discussed below, internal personnel monitoring for 

NNFD workers was for uranium exposures only. 

NIOSH has reviewed the records for a total of 64 BWXT claims with identifiable employment at 

NNFD. The number of energy employees monitored for internal exposures by bioassay or breathing 

zone air sampling for each operational period are shown in Table 5-1 below. 

Table 5-1: NNFD Energy Employees Internal Monitoring Information

BWXT Operational 

Period

No. of Energy Employees

Employed at NNFD

No. of Energy Employees

with No Internal Monitoring

Percentage Unmonitored or 

No Dose Record Available

1959 7 4 57%

1968 through 1972 42 3 7%

1985 through 2001 58 15 26%

The only bioassay sampling results obtained by NIOSH for NNFD workers were retrieved from 

individual-claim-related records; the samples were analyzed for uranium only. The numbers of 

samples available for evaluation are: 14 results for 1959; 232 results for 1968 through 1972; and 1190 

results for 1985 through 2001. For the latter period, 764 samples were analyzed for total uranium and 

426 were analyzed for isotopic uranium. 
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LTC Facility

Evaluation of LTC claim records indicates that, in addition to monitoring for uranium (using the same 

methods described above for NNFD), analyses were also performed in response to specific exposure 

situations or incidents. These analyses included plutonium urinalysis, fecal analysis for plutonium 

and americium, chest counts, and whole body counts consistent with the range of source term 

materials discussed in Section 5.6.

NIOSH has received records for a total of nine BWXT claims with identifiable employment at LTC. 

The number of energy employees monitored for internal exposures by operational period are shown in 

Table 5-2.

Table 5-2: LTC Energy Employees Internal Monitoring Information

BWXT Operational Period No. of Energy Employees

Employed at LTC

No. of Energy Employees with Internal Monitoring 

Records (Bioassay or Breathing Zone Samples)

1959 2 0

1968 through 1972 5 4

1985 through 2001 7 4

The only internal dose monitoring results obtained by NIOSH for LTC workers were obtained from 

individual-claim-related records and typically included urinalysis for uranium, whole body counts, or 

breathing zone samples, although numerous bioassay samples of various types were found for one 

worker in response to an exposure incident involving plutonium. A summary of the sample types and 

reported radionuclides obtained from individual worker records is provided in Table 5-3.

Table 5-3: LTC Energy Employees Internal Exposure Monitoring by Radionuclide and Type

Internal Monitoring Method Number of Analyses

1959 1968 – 1972 1985 - 2001

Urinalysis for total uranium 0 6 3

Urinalysis for isotopic uranium 0 5 3

Breathing zone 0 0 9

Whole body count for fission products 0 6 11

Lung count for uranium, plutonium, and americium 0 3a 10

Urinalysis for plutonium 0 34a 0

Fecal sample analysis for plutonium and americium 0 11a 0

Fecal sample analysis for uranium 0 7a 0

a Samples were for a single worker as part of an incident follow-up.

Information in site records and employee monitoring records does not contain information that 

clarifies whether the absence of monitoring records is due to missing records or due to the employee 

being removed from the monitoring program because of low exposure potential (although the latter is 

likely for claims during the last AWE operational period because there are external dose monitoring 

records available to NIOSH for the individuals).
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5.4 External Personnel Monitoring Data

NIOSH has identified external dose monitoring results from film and TLD badges during the 

AWE operations periods. In recent years, BWXT reported that external dose monitoring was 

discontinued for individuals due to lack of potential for exposures above the regulatory threshold for 

monitoring, and that many routine dosimetry badges were eliminated in 1994 in response to a revision 

to 10 C.F.R. 20, Standards for Protection Against Radiation (BWXT History, 2008). Records 

indicate that monitoring for most workers was suspended from 1996 through 1999 and in 2001.

Dosimeters were provided by Landauer from the beginning of operations through 2001 (BWXT 

History, 2008). Film badges were used until late 1990s when Luxel OSL badges were put in use until

2001. Global Dosimetry provided TLDs from 2001 to the present (BWXT History, 2008). The 

available energy employee data indicate that early monitoring may have also deployed pocket 

dosimeters.

NNFD Facility

NIOSH identified the following dosimeter types and exchange frequencies for NNFD based on 

evaluation of worker records:

• 1959-1991: film badges, monthly exchange 

• 1992: film badges, biannual exchange

• 1993-1999: film badges, annual exchange.

• 2000-Present: TLD badges, annual exchange

Monitoring was performed to assess exposures to photons and electrons for all years; neutron 

exposure was not significant for the materials involved in NNFD operations and did not require 

monitoring. 

NIOSH has reviewed the records of 64 BWXT claims with identifiable employment at NNFD. The 

number of energy employees monitored for external exposures for each operational period is shown in 

Table 5-4. The years 1996 through 1999 and 2001 were not included in the evaluation in Table 5-4 

because NNFD suspended dosimeters for most employees during those years, as discussed above. A 

breakdown of average and maximum worker annual doses is shown in Table 5-5. 

Table 5-4: NNFD Energy Employees External Monitoring Information

BWXT Operational 

Period

No. of Energy Employees

Employed at NNFD

No. of Energy Employees with 

No External Monitoring

Percentage Unmonitored or 

No Dose Record Available

1959 6 3 50%

1968 through 1972 43 3 6%

1985 through 2001 58 3 5%
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Table 5-5: NNFD Energy Employees Annual External Dose Summary

BWXT Operational 

Period

No. of Annual External 

Dose Records

Average Annual

Recorded Dose (rem)

Maximum Annual

Recorded Dose (rem)

1959 3 0.007 0.020

1968 23 0.033 0.160

1969 35 0.019 0.110

1970 37 0.051 0.610

1971 39 0.027 0.270

1972 39 0.022 0.190

1985 56 0.070 0.310

1986 54 0.035 0.370

1987 55 0.053 0.300

1988 55 0.024 0.150

1989 52 0.022 0.100

1990 49 0.019 0.150

1991 48 0.026 0.160

1992 45 0.042 0.340

1993 39 0.028 0.230

1994 39 0.040 0.430

1995 39 0.107 0.850

1996 8 0.070 0.140

1997 9 0.054 0.150

1998 6 0.072 0.180

1999 6 0.077 0.230

2000 26 0.121 0.661

2001 4 0.155 0.309

As discussed above, external dose monitoring was discontinued by BWXT during the last operational 

period for a number of individuals because of low exposure potential.

LTC Facility

At LTC, whole body badges were exchanged on a quarterly or monthly frequency based on the 

potential for higher doses due to fission products (BWXT History, 2008). Evaluation of records from 

personnel files and from Landauer verified that monitoring was performed to assess exposures to 

photons and electrons during all periods, and to assess exposures to neutrons for years during which 

the commercial reactors were operational. Available Landauer records include over 2200 pages of 

dosimetry data for the period from 1985 through 2001 (Dosimetry Reports, 1985 through 2001). 

NIOSH has received records for a total of nine BWXT claims with identifiable employment at LTC. 

The number of energy employees monitored for external exposures for each operational period is 

shown in Table 5-6. A breakdown of average and maximum worker annual doses is shown in Table 

5-7. 
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Table 5-6: LTC Energy Employees External Monitoring Information

BWXT Operational Period No. of Energy Employees Employed at LTC No. of Energy Employees With 

External Monitoring Records

1959 2 1

1968 through 1972 5 4

1985 through 2001 6 6

Table 5-7: LTC Energy Employees Annual External Dose Summary

BWXT Operational 

Period

No. of Annual External 

Dose Records

Average Annual

Recorded Dose (rem)

Maximum Annual

Recorded Dose (rem)

1959 1 N/A 3.285

1968 4 0.968 1.830

1969 4 0.423 0.790

1970 4 0.705 1.180

1971 4 0.603 1.140

1972 4 0.378 1.030

1985 3 0.058 0.110

1986 4 0.028 0.090

1987 5 0.040 0.100

1988 5 0.048 0.120

1989 5 0.032 0.090

1990 4 0.083 0.130

1991 4 0.075 0.160

1992 4 0.058 0.130

1993 2 0.015 0.020

1994 2 0.020 0.020

1995 1 N/A 0.090

1996 1 N/A 0.030

1997 0 N/A N/A

1998 1 N/A 0.030

1999 0 N/A N/A

2000 0 N/A N/A

2001 0 N/A N/A

Information in site records and employee monitoring records did not contain information that clarified

whether the absence of monitoring records was due to missing records or due to the employee being 

removed from the monitoring program because of low exposure potential.
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5.5 Workplace Monitoring Data

NIOSH has identified limited area dust sampling and breathing zone air sampling data, as discussed 

below.

5.5.1 Breathing zone air sampling

NIOSH has found nine breathing zone air sampling results beginning in 1989 (with the exception of 

one worker for whom results were recorded beginning in 1985). Prior to 1994, results were recorded 

in MPC-hours (Maximum Permissible Concentration). Following a 1994 revision to 10 C.F.R. 20, 

Standards for Protection Against Radiation, breathing zone sampling became a routine monitoring 

method, with results reported in DAC-hours (Derived Air Concentration) (BWXT History, 2008). 

Results were recorded for both alpha emitters and beta emitters.

5.5.2 Dust studies

A 1959 occupational air dust study conducted by the Health and Safety Laboratory (HASL-70, 1959) 

provides time-weighted airborne dust exposure data for two different commercial uranium-processing 

operations. The first study was performed on June 3-4, 1959 and included 153 workers involved in 

the Naval reactor uranium-zirconium fuel plate program. The second study included eight workers 

involved in the NYOO oxide pellet fabrication program (S.S. Savannah reactor fuel). No other 

information was found in the records outlining whether other operations were in progress or what air 

concentrations would have been outside of the limited scope of these evaluations (two days each).

5.6 Radiological Source Term Data

NNFD Source Term

The primary radionuclides that were sources of external and internal radiation exposure at the NNFD 

facility were uranium, typically enriched from 4% to over 90% U-235 (by mass), and Th-232 (BWXT 

History, 2008). Thorium was in use from the beginning of operations through February 1963 (BWXT 

History, undated); uranium has been processed at NNFD for all periods of operations.

LTC Source Term

The primary radionuclides that were sources of external and internal radiation exposure at the LTC 

facility were (BWXT History, 1994):

• fissile materials such as airborne enriched uranium, thorium, plutonium, and U-233

• transuranics

• irradiated fuels and materials

• fission and activation products 

In the records available to NIOSH, NIOSH has found no radioactive material inventory data that 

would enable it to place an upper bound on potential exposures to the wide array of commercial and 

AEC radiological sources that could have been encountered at the BWXT facilities.
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6.0 Feasibility of Dose Reconstruction for the Proposed Class

42 C.F.R. § 83.14(b) states that HHS will consider a NIOSH determination that there was insufficient 

information to complete a dose reconstruction, as indicated in this present case, to be sufficient,

without further consideration, to conclude that it is not feasible to estimate the levels of radiation 

doses of individual members of the class with sufficient accuracy. 

In the case of a petition submitted to NIOSH under 42 C.F.R. § 83.9(b), NIOSH has already 

determined that a dose reconstruction cannot be completed for an employee at the DOE or AWE 

facility. This determination by NIOSH provides the basis for the petition by the affected claimant. 

Per § 83.14(a), the NIOSH-proposed class defines those employees who, based on completed 

research, are similarly affected and for whom, as a class, dose reconstruction is similarly not feasible.

In accordance with § 83.14(a), NIOSH may establish a second class of co-workers at the facility for 

whom NIOSH believes that dose reconstruction is similarly infeasible, but for whom additional 

research and analysis is required. If so identified, NIOSH would address this second class in a 

separate SEC evaluation rather than delay consideration of the claim currently under evaluation (see 

Section 10). This would allow NIOSH, the Board, and HHS to complete, without delay, their 

consideration of the class that includes a claimant for whom NIOSH has already determined a dose 

reconstruction cannot be completed, and whose only possible remedy under EEOICPA is the addition 

of a class of employees to the SEC.

This section of the report summarizes research findings by which NIOSH determined that it lacked 

sufficient information to complete the relevant dose reconstruction and on which basis it has defined 

the class of employees for which dose reconstruction is not feasible. NIOSH’s determination relies on 

the same statutory and regulatory criteria that govern consideration of all SEC petitions. 

6.1 Feasibility of Estimating Internal Exposures

NIOSH has evaluated the available personnel and workplace monitoring data and source term 

information and has determined that there are insufficient data for estimating internal exposures, as 

described below.

NNFD Internal Exposures

Urine sampling for the first operational period used fluorometric analysis for evaluating uranium 

exposures to workers. As pointed out above, fluorometric analysis, which measures uranium by mass, 

is not capable of evaluating enriched uranium intakes unless a well-defined enrichment value is also 

known. Because enrichments at NNFD ranged from 4% percent to over 90% for all periods, and 

because available records do not provide adequately documented enrichment values for operations 

during this period, assessing worker doses due to enriched uranium intakes is infeasible for the period 

January 1, 1959 through December 31, 1959.

Additionally, with the exception of the 1959 feasibility study discussed in Section 5.3 (Feasibility 

Report, 1959), thorium exposures cannot be correlated to relative uranium amounts. Because no 

urinalysis or other evaluation of thorium exposure was performed, estimating worker doses due to 

thorium intakes is infeasible for the period January 1, 1959 through December 31, 1959.
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Records available to NIOSH include the 1959 occupational air dust study conducted by the Health and 

Safety Laboratory (HASL-70, 1959). However, NIOSH has no indication that air concentrations due 

to later operations would be comparable to those in the 1959 study; consequently, NIOSH is unable to 

use the 1959 air data to bound unmonitored internal exposures during the 1968 through 1972 AWE 

period at BWXT.

LTC Internal Exposures

High-activity commercial radioactive materials were handled and stored at various LTC locations 

(e.g., hot cells, Liquid Waste Disposal facility, irradiated fuel storage areas) (BWXT History, 1994). 

NIOSH has personnel monitoring records for one LTC worker that include routine bioassay analyses 

for uranium and fission products, and also include bioassays for plutonium and americium related to a 

1969 incident; these results indicate the potential for non-uranium exposures at LTC. 

In the absence of personnel monitoring data, NIOSH has not found sufficient general area air 

sampling, breathing zone air sampling, or other site survey information to allow it to bound potential 

exposures to commercial radioactive materials at the LTC facility during the AWE operational periods 

from January 1, 1959 through December 31, 1959, and from January 1, 1968 through December 31, 

1972.

LTC Infeasibility Applicability to NNFD Workers

Worker interviews (see Section 5.2) and other records indicate that some workers assigned to work at 

the NNFD site also worked a portion of their time at the LTC site; consequently, NIOSH is unable to 

adequately define individual exposure scenarios based on available records. As a result, potential 

intakes cannot be established for NNFD workers who may have also worked at LTC during the AWE 

operations periods from January 1, 1959 through December 31, 1959, and from January 1, 1968 

through December 31, 1972.

NIOSH does not have access to sufficient personnel monitoring, workplace monitoring, or source 

term data to estimate unmonitored internal exposures for BWXT workers during the periods of AWE 

operations from January 1, 1959 through December 31, 1959, or from January 1, 1968 through 

December 31, 1972, regardless of assigned work location.

Although NIOSH found that it is not possible to completely reconstruct internal radiation doses for the 

two specified AWE operations periods at BWXT, NIOSH intends to use any internal monitoring data 

that may become available for an individual claim (and that can be interpreted using existing NIOSH 

dose reconstruction processes or procedures). Dose reconstructions for individuals employed at 

BWXT during the periods from January 1, 1959, through December 31, 1959, or January 1, 1968, 

through December 31, 1972, but who do not qualify for inclusion in the SEC, may be performed using 

these data as appropriate.

6.2 Feasibility of Estimating External Exposures

This evaluation responds to a petition based on NIOSH determining that internal radiation exposures

could not be reconstructed for a dose reconstruction referred to NIOSH by the Department of Labor

(DOL). As noted above, HHS will consider this determination to be sufficient without further 

consideration to determine that it is not feasible to estimate the levels of radiation doses of individual 
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members of the class with sufficient accuracy. Consequently, it is not necessary for NIOSH to fully 

evaluate the feasibility of reconstructing external radiation exposures for the class of workers covered 

by this report.

External dose monitoring records for NNFD and LTC appear to be more complete than BWXT 

internal dose monitoring records, but some external data appear to be missing, especially for the 1959 

AWE operational period for which records could only be located for three of the six energy employees 

working at NNFD and one of the two workers at LTC during that year. Comprehensive Landauer 

dose reports are available for the 1985-2001 AWE operational period for LTC workers (Dosimetry 

Reports, 1985 through 2001). Consequently, NIOSH has found that external dose reconstruction is 

likely feasible for the latter AWE operational periods (1968 through 1972, and 1985 through 2001) for 

both NNFD and LTC workers.

Adequate reconstruction of medical dose is likely to be feasible by using claimant-favorable 

assumptions in the Technical Information Bulletin, Dose Reconstruction from Occupationally Related 

Diagnostic X-Ray Procedures (ORAUT-OTIB-0006).

Although NIOSH found that it is not possible to completely reconstruct radiation doses at BWXT, 

NIOSH intends to use any external monitoring data that may become available for an individual claim 

(and that can be interpreted using existing NIOSH dose reconstruction processes or procedures). Dose 

reconstructions for individuals employed at BWXT during the period from January 1, 1959 through 

December 31, 1959, or January 1, 1968 through December 31, 1972, but who do not qualify for 

inclusion in the SEC, may be performed using these data as appropriate.
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6.3 Class Parameters Associated with Infeasibility

Based on the information in Section 4.3, NIOSH assumes that AWE work at BWXT occurred during 

the periods from January 1, 1959 through December 31, 1959; from January 1, 1968 through 

December 31, 1972; and from January 1, 1985 through December 31, 2001. Based on the information 

in Section 6.0, NIOSH has determined that it has insufficient dose reconstruction information 

available for the two earlier AWE periods. Therefore, NIOSH recommends that the class include the 

time periods from January 1, 1959 through December 31, 1959, and from January 1, 1968 through 

December 31, 1972.

As presented in Sections 4.4 and 5.2, NIOSH has determined that workers sometimes travelled 

between the two BWXT sites, and NIOSH is not always able to determine an individual worker’s 

exposure potential using the available individual monitoring or employment records. NIOSH is 

unable to define individual worker exposure scenarios based on specific work assignments within the 

two BWXT facilities. NIOSH therefore recommends that the class definition include all buildings and 

areas of BWXT’s LTC and NNFD sites during the specified time periods.

NIOSH has insufficient information associating job titles and/or job assignments with specific 

radiological operations or conditions at the LTC and NNFD facilities of BWXT. Therefore, NIOSH 

recommends that the class include all BWXT workers during the specified time periods.

7.0 Summary of Feasibility Findings for Petition SEC-00169

This report evaluates the feasibility for completing dose reconstructions for employees of BWXT 

from January 1, 1959 through December 31, 1959, and from January 1, 1968 through December 31, 

1972. NIOSH determined that members of this class may have received internal and external 

radiation exposures from fission and activation products, uranium, and thorium. NIOSH lacks 

sufficient information, which includes insufficient biological monitoring data, air monitoring 

information, and process and radiological source information that would allow it to estimate the 

potential internal exposures to fission and activation products, uranium, and thorium to which the 

proposed class may have been exposed.

NIOSH has documented herein that it cannot complete the dose reconstruction related to this petition. 

The basis of this finding demonstrates that NIOSH does not have access to sufficient information to 

estimate either the maximum radiation dose incurred by any member of the class or to estimate such 

radiation doses more precisely than a maximum dose estimate.

Although NIOSH found that it is not possible to completely reconstruct radiation doses for the 

proposed class, NIOSH intends to use any internal and external monitoring data that may become 

available for an individual claim (and that can be interpreted using existing NIOSH dose 

reconstruction processes or procedures). Therefore, dose reconstructions for individuals employed at 

BWX Technologies, Inc., during the period from January 1, 1959 through December 31, 1959; 

January 1, 1968 through December 31, 1972, but who do not qualify for inclusion in the SEC, may be 

performed using these data as appropriate.
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8.0 Evaluation of Health Endangerment for Petition SEC-00169

The health endangerment determination for the class of employees covered by this evaluation report is 

governed by EEOICPA and 42 C.F.R. § 83.14(b) and § 83.13(c)(3). Pursuant to these requirements, if 

it is not feasible to estimate with sufficient accuracy radiation doses for members of the class, NIOSH 

must determine that there is a reasonable likelihood that such radiation doses may have endangered 

the health of members of the class. The regulations require NIOSH to assume that any duration of 

unprotected exposure may have endangered the health of members of a class when it has been 

established that the class may have been exposed to radiation during a discrete incident likely to have 

involved levels of exposure similarly high to those occurring during nuclear criticality incidents. If 

the occurrence of such an exceptionally high-level exposure has not been established, then NIOSH is 

required to specify that health was endangered for those workers who were employed for a number of 

work days aggregating at least 250 work days within the parameters established for the class or in 

combination with work days within the parameters established for one or more other classes of 

employees in the SEC. 

NIOSH has determined that members of the class were not exposed to radiation during a discrete 

incident likely to have involved levels of exposure similarly high to those occurring during nuclear 

criticality incidents. However, the evidence reviewed in this evaluation indicates that some workers in 

the class may have accumulated chronic radiation exposures through intakes of natural uranium, 

enriched uranium, and thorium and from direct exposure to radioactive materials. Consequently, 

NIOSH is specifying that health was endangered for those workers covered by this evaluation who 

were employed for a number of work days aggregating at least 250 work days within the parameters 

established for this class or in combination with work days within the parameters established for one 

or more other classes of employees in the SEC.

9.0 NIOSH-Proposed Class for Petition SEC-00169

The evaluation defines a single class of employees for which NIOSH cannot estimate radiation doses 

with sufficient accuracy. This class includes all AWE employees who worked at BWX Technologies, 

Inc. in Lynchburg, Virginia, during the periods:

• from January 1, 1959 through December 31, 1959; or

• from January 1, 1968 through December 31, 1972

for a number of work days aggregating at least 250 work days, occurring either solely under this 

employment, or in combination with work days within the parameters established for one or more 

other classes of employees included in the Special Exposure Cohort.
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10.0 Evaluation of Second Similar Class

In accordance with § 83.14(a), NIOSH may establish a second class of co-workers at the facility, 

similar to the class defined in Section 9.0, for whom NIOSH believes that dose reconstruction may not 

be feasible, and for whom additional research and analyses is required. If a second class is identified, 

it would require additional research and analyses. Such a class would be addressed in a separate SEC 

evaluation rather than delay consideration of the current claim. At this time, NIOSH has not identified 

a second similar class of employees at BWXT for whom dose reconstruction may not be feasible.
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11.0 References

10 C.F.R. pt. 20, Standards for Protection Against Radiation; U.S. Nuclear Regulatory Commission; 

Revised as of January 1, 2009; http://www.nrc.gov/reading-rm/doc-collections/cfr/

42 C.F.R. pt. 81, Guidelines for Determining the Probability of Causation Under the Energy 

Employees Occupational Illness Compensation Program Act of 2000; Final Rule, Federal 

Register/Vol. 67, No. 85/Thursday, p 22,296; May 2, 2002; SRDB Ref ID: 19391

42 C.F.R. pt. 82, Methods for Radiation Dose Reconstruction Under the Energy Employees 

Occupational Illness Compensation Program Act of 2000; Final Rule; May 2, 2002; SRDB Ref ID: 

19392

42 C.F.R. pt. 83, Procedures for Designating Classes of Employees as Members of the Special 

Exposure Cohort Under the Energy Employees Occupational Illness Compensation Program Act of 

2000; Final Rule; May 28, 2004; SRDB Ref ID: 22001

42 U.S.C. §§ 7384-7385 [EEOICPA], Energy Employees Occupational Illness Compensation 

Program Act of 2000; as amended; DCAS website

BWXT History, undated, EEOICPA Babcock and Wilcox Mount Athos Facility Early Operations 

with Uranium and Thorium Use, Babcock and Wilcox Technologies; date unknown, but from text 

after 1963; SDB Ref ID: 59890

BWXT History, 1994, EEOICPA Babcock and Wilcox Mount Athos Facility Lynchburg Technology 

Center Activities, Babcock and Wilcox Technologies; December 09, 1994; SRDB Ref ID: 74702

BWXT History, 2008, Babcock and Wilcox (BWXT) EEOICPA Supporting Information, Babcock and 

Wilcox Technologies; standard site history provided by the company in response to data requests; 

submitted to NOCTS July 11, 2008; SRDB Ref ID: 46822

BWXT History, 2009, Babcock and Wilcox – Main Site – Lynchburg Virginia at Mount Athos, 

Babcock and Wilcox Nuclear Operations Group, chronology of thorium-related actions; June 30, 

2009; SRDB Ref ID: 74755

DOE, 2010, Facility List Database, U. S. Department of Energy; Office of Health, Safety and 

Security; Energy Employees Occupational Illness Compensation Program; accessed 04-05-10; 

http://www.hss.energy.gov/healthsafety/fwsp/advocacy/faclist/showfacility.cfm

Dosimetry Reports, 1985, Babcock and Wilcox Company Radiation Dosimetry Report Account 69864; 

R.S. Landauer, Junior and Company; various dates between 1985 and 1986; SRDB Ref ID: 52580

Dosimetry Reports, 1986, Babcock and Wilcox Company Radiation Dosimetry Report Account 69864; 

R.S. Landauer, Junior and Company; various dates between 1986 and 1987; SRDB Ref ID: 52581

Dosimetry Reports, 1987, Babcock and Wilcox Company Radiation Dosimetry Report Account 69864; 

R.S. Landauer, Junior and Company; various dates between 1987 and 1988; SRDB Ref ID: 52582
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Dosimetry Reports, 1988, Babcock and Wilcox Company Radiation Dosimetry Report Account 69864; 

R.S. Landauer, Junior and Company; various dates between 1988 and 1989; SRDB Ref ID: 52583

Dosimetry Reports, 1989, Babcock and Wilcox Company Radiation Dosimetry Report Account 69864; 

R.S. Landauer, Junior and Company; various dates between 1989 and 1990; SRDB Ref ID: 52585

Dosimetry Reports, 1990, Babcock and Wilcox Company Radiation Dosimetry Report Account 69864; 

R.S. Landauer, Junior and Company; various dates between 1990 and 1991; SRDB Ref ID: 52589

Dosimetry Reports, 1991, Babcock and Wilcox Company Radiation Dosimetry Report Account 69864; 

R.S. Landauer, Junior and Company; various dates between 1991 and 1992; SRDB Ref ID: 52595

Dosimetry Reports, 1992, Babcock and Wilcox Company Radiation Dosimetry Report Account 69864; 

R.S. Landauer, Junior and Company; various dates between 1992 and 1993; SRDB Ref ID: 52596

Dosimetry Reports, 1993, Babcock and Wilcox Company Radiation Dosimetry Report Account 69864; 

R.S. Landauer, Junior and Company; various dates in 1993; SRDB Ref ID: 52597

Dosimetry Reports, 1994, Babcock and Wilcox Company Radiation Dosimetry Report Account 69864; 

R.S. Landauer, Junior and Company; various dates in early 1995; SRDB Ref ID: 52598

Dosimetry Reports, 1995, Babcock and Wilcox Company Radiation Dosimetry Report Account 69864; 

R.S. Landauer, Junior and Company; various dates in 1996; SRDB Ref ID: 52600

Dosimetry Reports, 1996, Babcock and Wilcox Company Radiation Dosimetry Report Account 69864; 

R.S. Landauer, Junior and Company; various dates in 1996; SRDB Ref ID: 52602

Dosimetry Reports, 1997, Babcock and Wilcox Company Radiation Dosimetry Report Account 69864; 

R.S. Landauer, Junior and Company; various dates in 1997; SRDB Ref ID: 52605

Dosimetry Reports, 1998, Babcock and Wilcox Company Radiation Dosimetry Report Account 69864; 

R.S. Landauer, Junior and Company; various dates in 1998; SRDB Ref ID: 52606

Dosimetry Reports, 1999, Babcock and Wilcox Company Radiation Dosimetry Report Account 69864; 

R.S. Landauer, Junior and Company; various dates in 1999; SRDB Ref ID: 52607

Dosimetry Reports, 2000, Babcock and Wilcox Company Radiation Dosimetry Report Account 69864; 

R.S. Landauer, Junior and Company; various dates in 2000; SRDB Ref ID: 52608

Dosimetry Reports, 2001, Babcock and Wilcox Company Radiation Dosimetry Report Account 69864; 

R.S. Landauer, Junior and Company; various dates between 2001 and 2002; SRDB Ref ID: 52609

Feasibility Report, 1959, The Babcock and Wilcox Company Nuclear Facilities Plant, Lynchburg, 

Virginia; Feasibility Report No. 10, U. S. Atomic Energy Commission, Chicago Operations Office, 

Argonne National Laboratory; July 17, 1959; SRDB Ref ID: 74811

Frazier, 1956, memo to the files, Telephone Call to Mr. Al Breslin, New York Operations Office, 

USAEC, P. M. Frazier; call to discuss thorium radiation safety; April 4, 1956; SRDB Ref ID: 74762
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HASL-70, 1959, Occupational Exposure to Radioactive Dust; U.S. Atomic Energy Commission, New 

York Operations Office; October 26, 1959; SRDB Ref ID: 14533

HP Report, October 1956, Health-Physics Report for Week October 8, 1956, Frazier; Babcock and 

Wilcox Technologies; October 17, 1956; SRDB Ref ID: 74771

HP Report, November 1956, Health-Physics Report for Period November 5 – 30, 1956, Frazier; 

December 06, 1956; SRDB Ref ID: 74784

License Termination, 1986, License Termination Survey Report for the CX-10 Critical Experiment 

Facility at Lynchburg Research Center, Lynchburg, Virginia, Babcock & Wilcox, Research and 

Development Division; June 1986; SRDB Ref ID: 75704 

Materials License, 1987, SNM-778, Amendment No. 1, from U. S. Nuclear Regulatory Commission to 

Babcock & Wilcox Naval Nuclear Division, 1987; SRDB Ref ID: 74703

NucNews, 2002, NucNews – December 31, 2002, http://nucnews.net/nucnews/2002nn/0212nn/ 

02123nn.htm; accessed January 30, 2008; SRDB Ref ID: 42192

NucNews, 2003, NucNews – January 1, 2003, http://nucnews.net/nucnews/2003nn/0301nn/ 

03010nn.htm; accessed January 29, 2008; SRDB Ref ID: 42191

ORAUT-OTIB-0006, Dose Reconstruction from Occupationally Related Diagnostic X-Ray 

Procedures, Rev. 03 PC-1; Oak Ridge Associated Universities (ORAU); Oak Ridge, Tennessee; 

December 21, 2005; SRDB Ref ID: 20220

Personal Communication, 2010a, Personal Communication with BWXT Health Physicist; Telephone 

Interview by ORAU Team; March 11, 2009; SRDB Ref ID: 61504 

Personal Communication, 2010b, Personal Communication with various BWXT employees; 

Telephone Interview by ORAU Team; March 23-25, 2010; SRDB Ref ID: 80148 

Personal Communication, 2010c, Personal Communication with a BWXT employee; Telephone 

Interview by ORAU Team; March 30, 2010; SRDB Ref ID: 80182 

Public Hearings, 1959, Public Hearings on Industrial Radioactive Waste Disposal, January 28, 29, 30 

and February 2,3, 1959, Paper for the Record on Nature of Wastes in Fuel Element Manufacture, 

Jessen; Babcock and Wilcox Company; January 07, 1959; SRDB Ref ID: 74795

Sapphire, undated, The SAPPHIRE and 50 MT Projects at BWXT, Lynchburg, VA, symposium paper 

written by R. Thiele (IAEA), B. Horn, C. W. Coates, and J. R. Stainback; to be presented by R. 

Thiele; International Atomic Energy Agency (IAEA); IAEA-SM-367/8/01/P; undated; SRDB Ref ID: 

40730
SEC-00169 04-28-10 BWXT

30 of 43

Shipment Analysis, 1969, Analysis of Uranium Shipment #101, Hobson; March 31, 1969; SRDB Ref 

ID: 43868

Shipment Request, 1959, Requests to Ship Nuclear Material Made to U.S. Atomic Energy Commission 

and Responses; May 8-15, 1959; SRDB Ref ID: 56321
SEC-00169 04-28-10 BWXT

Page 31 of 43

Attachment One: Data Capture Synopsis

Table A1-1: Summary of Holdings in the SRDB for BWX Technologies, Inc.

Data Capture Information General Description of Documents Captured Date 

Completed

Uploaded into 

SRDB

Primary Site/Company Name: BWX Technologies, Inc.

AWE 1959; 1968-1972 & 1985-2001; Res. Rad. 1960-

1967; 1973-1984; & 2002-July 2006; BE 1995-2001 

Other Site Names: 

Tubular Products Div., Lone Star Tech

Babcock & Wilcox Co.

BWXT 

Process knowledge write-up of Babcock and Wilcox Mount Athos 

Facility early operations with uranium and thorium. 

02/19/2009 1

State Contacted: Les Foldesi and Mike Welling, Virginia 

Department of Health

Composite environmental air samples and radioisotopes, forms, and 

possession limits from radioactive materials license 45-00105-01.

10/23/2009 3

DOE Germantown Contract AT(30-1)-4220 transmittal letters. Unknown 1

DOE Legacy Management - Grand Junction Office AEC licensing and contract documents, description of the Lynchburg 

Technology Center (LTC), survey and decommissioning reports for 

LTC Buildings A and C, thorium inventories and work descriptions at 

the Mt. Athos facility, health physics activities reports, and Landauer 

correspondence on anomalous film badge readings. 

10/20/2009 44

DOE Legacy Management - MoundView (Fernald 

Holdings, includes Fernald Legal Database)

Shipment records for thorium and enriched uranium received at Fernald 

from BWXT, disposition order transferring enriched uranium standards 

to BWXT from Fernald, and a report of plutonium contamination in 

UO2 received at Fernald from various sites, including BWXT.

06/30/2008 5

Hanford A 1971 Hanford monthly report including plutonium receipts from 

BWXT.

11/24/2008 1

Internet - DOE Comprehensive Epidemiologic Data 

Resource (CEDR)

No relevant data identified. 11/06/2009 0

Internet - DOE Hanford Declassified Document Retrieval 

System (DDRS)

Hanford progress reports that mention that B&W was working on the 

aluminum corrosion problem and the development of fuel for the heavy 

water reactor.

11/06/2009 2

Internet - DOE OpenNet No relevant data identified. 11/04/2009 0

Internet - DOE OSTI Energy Citations No relevant data identified. 03/28/2008 0

Internet - DOE OSTI Information Bridge Records of Sapphire material including U-232 content, downblending 

highly enriched UF6, low-level waste report including a brief history of 

BWXT plutonium operations, mention of BWXT as a vendor of 

pressurized water reactors in a mixed oxide fuel report, and an aerial 

radiological survey of the facility and its environs.

01/08/2008 8

Internet - DOE OSTI Science Accelerator No relevant data identified. 11/05/2009 0
SEC-00169 04-28-10 BWXT

32 of 43

Table A1-1: Summary of Holdings in the SRDB for BWX Technologies, Inc.

Data Capture Information General Description of Documents Captured Date 

Completed

Uploaded into 

SRDB

Internet - Google A report on the Sapphire and 50-MT downblending projects, news 

reports on BWXT's business prospects and a criticality violation, site 

decommissioning plans, licensing correspondence, DOE occupational 

exposure reports, environmental reports, and a mixed oxide fuel report.

11/06/2009 42

Internet - National Academies Press (NAP) No relevant data identified. 11/06/2009 0

Internet - National Nuclear Security Administration 

(NNSA) - Nevada Site Office

No relevant data identified. 11/04/2009 0

Internet - NRC Agencywide Document Access and 

Management (ADAMS)

Environmental assessments, safety evaluation report on the container 

storage facility, final generic environmental statement on the use of 

recycled plutonium in mixed oxide fuel reactors, inspection report with 

a criticality safety notice of violation, license application and Oak Ridge 

National Laboratory license report regarding the rolling and machining 

of B&W thorium ingots at Jessop Steel, NRC license SNM-42 

amendments, and a license application for the rolling and machining of 

B&W thorium ingots at Superior Steel Corporation. 

11/06/2009 23

Internet - Washington State University (U.S. Transuranium 

and Uranium Registries)

No relevant data identified. 11/06/2009 0

NOCTS Description of the dosimetry program and the availability of dosimetry 

records.

07/21/2008 1

NRC Records Listing of fuel fabricators and processors including summary group 

dose information, 1982-2001.

07/13/2005 1

ORAU Team Documented communications regarding a BWXT process knowledge 

interview and a request for BWXT documents held by the Grand 

Junction Operations Office.

10/19/2009 2

R.S. Landauer External dosimetry reports from 1975-2001. 08/19/2008 28

SAIC Summary of radiation exposures. 09/02/2004 1

Unknown New York Operations Office (NYOO) reports mentioning the Babcock 

& Wilcox (B&W) proposal to alter the Brookhaven graphite pile 

structure, NYOO reports of B&W enriched uranium inventories, air 

dust analysis cards from 1959-1961, Health and Safety Laboratory air 

dust study at B&W, and project spreadsheets.

Unknown 7

Westinghouse Site, Hematite, MO Records of fuel shipments from United Nuclear to B&W, an exposure 

history for a United Nuclear employee provided to B&W, and a report 

of a proposed enforcement action against B&W for criticality safety 

violations. 

04/07/2009 3

TOTAL 173
SEC-00169 04-28-10 BWXT

33 of 43

Table A1-2: Internet Database Searches for BWX Technologies, Inc.

Database/Source Keywords/Phrases Hits Uploaded into 

SRDB

DOE CEDR

http://cedr.lbl.gov/

COMPLETED 11/06/2009

BWX

"Tubular Products"

SNM-42 OR License

0 0

DOE Hanford DDRS

http://www2.hanford.gov/declass/

COMPLETED 11/06/2009

"BWXT"

"Babcock & Wilcox"

BWXT

BWX

1 2 

(Added during 

Hanford site 

association 

review)

DOE OpenNet

http://www.osti.gov/opennet/advancedsearch.jsp

COMPLETED 11/04/2009

BWXT

Tubular Products

Lone Star

Babcock & Wilcox

BWX

54 0

DOE OSTI Energy Citations

http://www.osti.gov/energycitations/

COMPLETED 03/28/2008

Tubular Products Div.

Lone Star Tech

BWXT "weapons scrap"

BWXT "oxide pellet"

BWXT "Project Sapphire"

BWXT "Fernald"

BWXT "Kazakhstan"

BWXT "FMPC"

Babcock & Wilcox "Project Sapphire"

Babcock & Wilcox "weapons scrap"

Babcock & Wilcox "oxide pellet"

Babcock & Wilcox "Fernald"

Babcock & Wilcox "Kazakhstan"

Babcock & Wilcox "FMPC"

SNM-42

BWX

Docket 70-27

SNM-16

SNM-32

C-3465

C-3473

C-3555

45-105-4 (E60)

45-105-3

111 0
SEC-00169 04-28-10 BWXT

34 of 43

Table A1-2: Internet Database Searches for BWX Technologies, Inc.

Database/Source Keywords/Phrases Hits Uploaded into 

SRDB

DOE OSTI Science Accelerator

http://www.scienceaccelerator.gov/

COMPLETED 11/05/2009

SNM-42

BWX

Docket 70-27

SNM-16

SNM-32

C-3465

C-3473

C-3555

45-105-4 (E60)

45-105-3

110 0

Google

http://www.google.com

COMPLETED 11/06/2009

BWXT "Lynchburg"

Babcock & Wilcox "lynchburg"

Babcock & Wilcox "lynchburg" "nuclear" 

babcock & wilcox "lynchburg" 1955 1956 1957 1958 1959

Kellex "Lynchburg"

atomic energy commission "babcock" "lynchburg"

BWXT "NRC"

BWXT "lynchburg""Americium"

BWXT "lynchburg""Americium"

BWXT lynchburg "Am241" OR, "Am-241" OR "AM 241" OR 

"241Am" OR "241-Am" OR "241 Am"

bwxt lynchburg "Th230", OR "Th-230", OR "Th OR 230", OR 

"230Th", OR "230-Th", OR "230 Th"

"bwxt"lynchburg""th230"

"bwxt"lynchburg""th-230"

"bwxt"lynchburg""th 230"

"bwxt"lynchburg""230th"

"bwxt"lynchburg""230-th"

"bwxt"lynchburg""230 th"

"bwxt"lynchburg""Thorium"

"bwxt"lynchburg""Neptunium"

"bwxt"lynchburg""Polonium"

"bwxt"lynchburg""Ionium"

"BWXT""Lynchburg""AEC"

47,391 42
SEC-00169 04-28-10 BWXT

35 of 43

Table A1-2: Internet Database Searches for BWX Technologies, Inc.

Database/Source Keywords/Phrases Hits Uploaded into 

SRDB

“BWX Technologies” AND americium OR Am241 OR Am-241 OR 

Am 241 OR 241Am OR 241-Am OR 241 Am -EEOICPA -ORAU –

NIOSH

"BWX Technologies" AND ionium OR Th230 OR Th-230 OR Th 230 

OR 230Th OR 230-Th OR 230 Th -EEOICPA -ORAU –NIOSH

"BWX Technologies" AND neptunium OR Np237 OR Np-237 OR Np 

237 OR 237Np OR 237-Np OR 237 Np OR palm OR palmolive -

EEOICPA -ORAU –NIOSH

"BWX Technologies" AND polonium OR Po210 OR Po-210 OR Po 

210 OR 210Po OR 210-Po OR 210 Po -EEOICPA -ORAU -NIOSH

"BWX Technologies" AND thorium OR thoria OR Th232 OR Th-232 

OR Th 232 OR 232Th OR 232-Th OR 232 Th OR Z metal OR Z-metal 

-EEOICPA -ORAU –NIOSH

"BWX Technologies" AND myrnalloy OR chemical 10-66 OR 

chemical 1066 OR chemical 10 66 OR chemical 18-12 OR chemical 

1812 -EEOICPA -ORAU –NIOSH

"BWX Technologies" AND OR chemical 18 12 OR chemical 10-12 

OR chemical 1012 OR chemical 10 12 OR UX1 OR UX2 -EEOICPA -

ORAU –NIOSH

"BWX Technologies" AND Th-234 OR Th234 OR Th 234 OR 234-Th 

OR 234Th OR 234 Thtritium OR H3 OR H-3 OR mint OR HTO -

EEOICPA -ORAU –NIOSH

"BWX Technologies" AND uranium OR U233 OR U-233 OR U 233 

OR 233U OR 233-U OR 233 U OR U234 OR U 234 OR U-234 -

EEOICPA -ORAU –NIOSH

"BWX Technologies" AND 234U OR 234-U OR 234 U OR U235 OR 

U 235 OR U-235 OR 235-U OR 235U OR 235 U -EEOICPA -ORAU –

NIOSH
SEC-00169 04-28-10 BWXT

36 of 43

Table A1-2: Internet Database Searches for BWX Technologies, Inc.

Database/Source Keywords/Phrases Hits Uploaded into 

SRDB

"BWX Technologies" AND U238 OR U 238 OR U-238 OR 238-U OR 

238U OR 238 U OR U308 OR U 308 OR U-308 OR 308-U -EEOICPA 

-ORAU –NIOSH

"BWX Technologies" AND 308U OR 308 U OR black oxide OR 

brown oxide OR green salt OR orange oxide OR yellow cake OR UO2 -

EEOICPA -ORAU –NIOSH

"BWX Technologies" AND UO3 OR UF4 OR UF6 OR C-216 -

EEOICPA -ORAU –NIOSH

"BWX Technologies" AND C-616 OR C-65 OR C-211 OR U3O8 

(uranium extraction OR uranium dioxide OR uranium hexafluoride OR 

uranium tetrafluoride OR uranium trioxide) -EEOICPA -ORAU –

NIOSH

"BWX Technologies" AND plutonium OR Pu-238 OR Pu238 OR Pu 

238 OR 238Pu OR 238-Pu OR 238 Pu OR Pu-239 OR Pu239 OR Pu 

239 OR 239Pu OR 239-Pu -EEOICPA -ORAU –NIOSH

"BWX Technologies" AND 239 Pu OR Pu-240 OR Pu240 OR Pu 240 

OR 240Pu OR 240-Pu OR 240 Pu OR Pu-241 OR Pu241 -EEOICPA -

ORAU –NIOSH

"BWX Technologies" AND Pu 241 OR 241Pu OR 241-Pu OR 241 Pu -

EEOICPA -ORAU –NIOSH

"BWX Technologies" AND radium OR Ra-226 OR Ra226 OR Ra 226 

OR 226-Ra OR 226Ra OR 226 Ra OR Ra-228 OR Ra228 -EEOICPA -

ORAU –NIOSH

"BWX Technologies" AND Ra 228 OR 228Ra OR 228-Ra OR 228 Ra -

EEOICPA -ORAU –NIOSH

"BWX Technologies" AND radon OR Rn-222 OR Rn222 OR Rn 222 

OR 222Rn OR 222-Rn OR 222 Rn -EEOICPA -ORAU –NIOSH
SEC-00169 04-28-10 BWXT

37 of 43

Table A1-2: Internet Database Searches for BWX Technologies, Inc.

Database/Source Keywords/Phrases Hits Uploaded into 

SRDB

"BWX Technologies" AND thoron OR Rn-220 OR Rn220 OR Rn 220 

OR 220Rn OR 220-Rn OR 220 Rn -EEOICPA -ORAU –NIOSH

"BWX Technologies" AND protactinium OR Pa-234m OR Pa234m OR 

Pa 234m OR 234mPa OR 234m-Pa OR 234m Pa -EEOICPA -ORAU –

NIOSH

“BWX Technologies" AND strontium OR Sr-90 OR Sr90 OR Sr 90 OR 

90-Sr OR 90Sr OR 90 Sr OR oralloy -EEOICPA -ORAU –NIOSH

"BWX Technologies" AND postum OR tuballoy OR uranyl nitrate 

hexahydrate OR UNH OR K-65 OR sump cake OR accident OR air 

count OR air dust OR air filter -EEOICPA -ORAU –NIOSH

"BWX Technologies" AND airborne test OR alpha OR belgian congo 

ore OR beta OR bioassay OR bio-assay OR breath OR breathing zone 

OR BZ OR body burden -EEOICPA -ORAU -NIOSH

"BWX Technologies" AND contamination OR curie OR denitration OR 

denitration pot OR derby OR regulus OR derived air concentration OR 

DAC OR dose -EEOICPA -ORAU –NIOSH

"BWX Technologies" AND calibration OR chest count OR 

columnation OR dosimeter OR dosimetric OR dosimetry OR electron -

EEOICPA -ORAU –NIOSH

"BWX Technologies" AND environment OR Ether-Water Project OR 

exposure (exposure investigation OR radiation exposure) OR external 

OR F machine OR fecal OR feed material OR femptocurie OR film OR 

fission -EEOICPA -ORAU –NIOSH

"BWX Technologies" AND fluoroscopy OR Formerly Utilized Sites 

Remedial Action Program OR FUSRAP OR gamma-ray OR gamma ray 

OR gas proportional -EEOICPA -ORAU –NIOSH

"BWX Technologies" AND gaseous diffusion OR health (health 

instrument OR health physics) OR H.I. OR HI OR HP OR highly 

enriched uranium -EEOICPA -ORAU –NIOSH
SEC-00169 04-28-10 BWXT

38 of 43

Table A1-2: Internet Database Searches for BWX Technologies, Inc.

Database/Source Keywords/Phrases Hits Uploaded into 

SRDB

"BWX Technologies" AND HEU OR hydrofluorination OR in vitro OR 

in vivo -EEOICPA -ORAU –NIOSH

"BWX Technologies" AND fluoroscopy OR Formerly Utilized Sites 

Remedial Action Program OR FUSRAP OR gamma-ray OR gamma ray 

OR gas proportional OR gaseous diffusion -EEOICPA -ORAU –

NIOSH

"BWX Technologies" AND health (health instrument OR health 

physics) OR H.I. OR HI OR HP OR highly enriched uranium OR HEU 

OR hydrofluorination OR in vitro OR in vivo -EEOICPA -ORAU –

NIOSH

"BWX Technologies" AND incident OR ingestion OR inhalation OR 

internal OR investigation OR isotope OR isotopic OR isotopic 

enrichment OR JS Project OR Landauer -EEOICPA -ORAU –NIOSH

"BWX Technologies" AND contamination OR curie OR denitration OR 

denitration pot OR derby OR regulus OR derived air concentration OR 

DAC OR dose -EEOICPA -ORAU –NIOSH

"BWX Technologies" AND calibration OR chest count OR 

columnation OR dosimeter OR dosimetric OR dosimetry OR electron -

EEOICPA -ORAU –NIOSH

"BWX Technologies" AND environment OR Ether-Water Project OR 

exposure (exposure investigation OR radiation exposure) OR external 

OR F machine OR fecal OR feed material OR femptocurie OR film OR 

fission -EEOICPA -ORAU –NIOSH

"BWX Technologies" AND fluoroscopy OR Formerly Utilized Sites 

Remedial Action Program OR FUSRAP OR gamma-ray OR gamma ray 

OR gas proportional -EEOICPA -ORAU –NIOSH

"BWX Technologies" AND gaseous diffusion OR health (health 

instrument OR health physics) OR H.I. OR HI OR HP OR highly 

enriched uranium -EEOICPA -ORAU –NIOSH
SEC-00169 04-28-10 BWXT

39 of 43

Table A1-2: Internet Database Searches for BWX Technologies, Inc.

Database/Source Keywords/Phrases Hits Uploaded into 

SRDB

"BWX Technologies" AND HEU OR hydrofluorination OR in vitro OR 

in vivo -EEOICPA -ORAU –NIOSH

"BWX Technologies" AND fluoroscopy OR Formerly Utilized Sites 

Remedial Action Program OR FUSRAP OR gamma-ray OR gamma ray 

OR gas proportional OR gaseous diffusion -EEOICPA -ORAU -NIOSH

"BWX Technologies" AND health (health instrument OR health 

physics) OR H.I. OR HI OR HP OR highly enriched uranium OR HEU 

OR hydrofluorination OR in vitro OR in vivo -EEOICPA -ORAU –

NIOSH

"BWX Technologies" AND incident OR ingestion OR inhalation OR 

internal OR investigation OR isotope OR isotopic OR isotopic 

enrichment OR JS Project OR Landauer -EEOICPA -ORAU –NIOSH

"BWX Technologies" AND liquid scintillation OR log (log sheet OR 

log book) OR low enriched uranium OR LEU OR lung count OR 

maximum permissible concentration OR MPC -EEOICPA -ORAU –

NIOSH

"BWX Technologies" AND metallurgy OR microcurie OR millicurie 

OR mixed fission product OR MFP OR monitor (air monitoring) -

EEOICPA -ORAU –NIOSH

"BWX Technologies" AND nanocurie OR nasal wipe OR neutron OR 

nose wipe OR nuclear (Chicago-Nuclear OR nuclear fuels) OR nuclear 

track emulsion type A -EEOICPA -ORAU –NIOSH

"BWX Technologies" AND NTA OR occupational radiation exposure 

OR occurrence OR ore concentrate OR PC Project -EEOICPA -ORAU 

–NIOSH

"BWX Technologies" AND permit (radiation work permit OR safe 

work permit OR special work permit) OR RWP OR SWP OR 

phosphate research OR photon -EEOICPA -ORAU –NIOSH
SEC-00169 04-28-10 BWXT

40 of 43

Table A1-2: Internet Database Searches for BWX Technologies, Inc.

Database/Source Keywords/Phrases Hits Uploaded into 

SRDB

"BWX Technologies" AND picocurie OR pitchblende OR pocket ion 

chamber OR PIC OR problem OR procedure OR radeco OR radiation -

EEOICPA -ORAU –NIOSH

"BWX Technologies" AND radioactive OR radioactivity OR 

radiograph OR radiological OR Radiological Survey Data Sheet OR 

RSDS OR radionuclide OR raffinate OR reactor OR respiratory OR

retention schedules -EEOICPA -ORAU –NIOSH

"BWX Technologies" AND roentgen OR sample (air sample OR dust 

sample OR general area air sample) OR sampling (air sampling OR dust 

sampling OR general area air sampling) -EEOICPA -ORAU –NIOSH

"BWX Technologies" AND solvent extract+B31ion OR source (sealed 

source) OR spectra OR spectrograph OR spectroscopy OR spectrum 

OR standard (operating OR processing OR etc) -EEOICPA -ORAU –

NIOSH

"BWX Technologies" AND survey (building survey OR routine OR 

special) OR technical basis OR thermal diffusion OR 

thermoluminescent dosimeter OR TLD OR Tiger Team -EEOICPA -

ORAU –NIOSH

"BWX Technologies" AND tolerance dose OR urinalysis OR urine OR 

whole body count OR WBC OR working level OR WL OR X-ray OR 

X ray OR Xray -EEOICPA -ORAU –NIOSH

"Lone Star Tech" AND Virginia -EEOICPA -NIOSH -ORAU

"Tubular Products"" AND Virginia AND Lynchburg -EEOICPA -

NIOSH –ORAU

SNM-42

Docket 70-27

SNM-16 AND license AND Virginia AND Lynchburg -EEOICPA -

ORAU –NIOSH
SEC-00169 04-28-10 BWXT

41 of 43

Table A1-2: Internet Database Searches for BWX Technologies, Inc.

Database/Source Keywords/Phrases Hits Uploaded into 

SRDB

SNM-32 AND license AND Virginia AND Lynchburg -EEOICPA -

ORAU –NIOSH

C-3465 AND license AND Virginia AND Lynchburg -EEOICPA -

ORAU –NIOSH 

C-3473 AND license AND Virginia AND Lynchburg -EEOICPA -

ORAU –NIOSH

C-3555 AND license AND Virginia AND Lynchburg -EEOICPA -

ORAU –NIOSH

45-105-4 (E60) AND license AND Virginia AND Lynchburg -

EEOICPA -ORAU –NIOSH

45-105-3 AND license AND Virginia AND Lynchburg -EEOICPA -

ORAU –NIOSH

"Ken Conway" AND Babcock

National Academies Press

http://www.nap.edu/

COMPLETED 11/06/2009

BWXT

BWX

18 0

National Archives 

http://www.archives.gov/research/arc/

COMPLETED 03/28/2008

BWXT

BWX Technologies, Inc

BWX Technologies

Babcock & Wilcox Co.

Babcock & Wilcox

Tubular Products Div.

Tubular Products

Lone Star Tech

33 0

NNSA - Nevada Site Office

www.nv.doe.gov/main/search.htm

COMPLETED 11/04/2009

BWX Technologies, Inc

BWX Technologies

Babcock & Wilcox Co.

Babcock & Wilcox

Tubular Products Div.

Tubular Products

Lone Star Tech

BWXT
SEC-00169 04-28-10 BWXT

42 of 43

Table A1-2: Internet Database Searches for BWX Technologies, Inc.

Database/Source Keywords/Phrases Hits Uploaded into 

SRDB

BWX

Docket 70-27

SNM-42

NRC ADAMS Reading Room

http://www.nrc.gov/reading-rm/adams/web-based.html

COMPLETED 11/06/2009

Tubular Products; filter by Virginia

Lone Star Tech

BWX Technologies, Inc

oxide pellet

enriched uranium

fernald

weapons scrap

project sapphire

environmental monitoring

environmental monitoring

oxide pellet

enriched uranium

fernald

weapons scrap

project sapphire

SNM-42 (Restricted by date: 01/01/1959-12/31/2006)

SNM-42 (Restricted by Docket 70)

SNM-16

SNM-32

C-3465

C-3473

C-3555

45-105-4 (E60) (Filtered with BWX)

45-105-3

2,186 23

U.S. Transuranium & Uranium Registries 

http://www.ustur.wsu.edu/

COMPLETED 11/06/2009

BWX Technologies, Inc

BWX Technologies

Babcock & Wilcox Co.

Babcock & Wilcox

Tubular Products Div.

Tubular Products 

Lone Star Tech

BWX

SNM-42
SEC-00169 04-28-10 BWXT

43 of 43

Table A1-3: OSTI Documents Requested for BWX Technologies, Inc.

Document Number Document Title Requested Date Received Date

BAW-4228-1 Research and Development Programs on Plutonium Fuels Technology, 

Feb 1, 1971

11/10/2009 

BAW-4228-2 Research and Development Programs on Plutonium Fuels Technology, 

Report No. 2, Aug 1, 1971

11/10/2009 

BAW-1322 Advanced Test Reactor Internals Vibration Summary, May 1968 dated 

Jun 1, 1968

11/10/2009